C3 Public Safety

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Appendix C3C3-1 Chronological List of LNG AccidentsC3-2 Marine Safety and Security Requirements

C3-3 Design and Safety Standards Applicable toNatural Gas Projects


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Cabrillo Port LNG Deepwater Port March 2006

C3-1

CHRONOLOGICAL LIST OF LNG

ACCIDENTS


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March 2006 C3.1-1 Cabrillo Port Liquefie

CHRONOLOGICAL LIST OF LNG ACCIDENTS

Major LNG Incidents

Incident

Date

Ship/Facility

Name

LocationShip

Status

Injuries/

Fatalities

Ship/Property

Damage

LNG Spill /

Release

Comment

1944East Ohio GasLNG Tank

Cleveland,Ohio, US

NA128deaths

NA NA

LNG peakshaearthen bermsurrounding sNatural gas in

1965CanveyIsland, UK

A transferoperation

1seriouslyburned

Yes

1965 J ules Vernet Loading No Yes Yes Overfilling. Ta

1965MethanePrincess

Disconnecting afterdischarge

No Yes Yes Valve leakage

1971

LNG ship EssoBrega, LaSpezia LNGImport Terminal

Italy

UnloadingLNG intothestoragetank

NA NA Yes

First documedeveloped a svapor discharvents. Tank ro

1973Texas EasternTransmission,LNG Tank

StatenIsland, NY,US

NA 40 killed No No

Industrial incidLNG (construcvapors assocapparently igntemperature ienough pressconcrete roofthe tank.

1973CanveyIsland, UK

NA No Yes Yes

Glass breakaupon a puddleflameless vaptransition (RPinjuries result

1974 Massachusetts Loading No Yes Yes Valve leakage


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Major LNG Incidents

IncidentDate

Ship/FacilityName

LocationShipStatus

Injuries/Fatalities

Ship/PropertyDamage

LNG Spill /Release

Comment

1974Methane

Princess

In port No Yes No Touched bott

1975PhiladelphiaGas Works

NA No Yes NANot caused bheat transfer entire vaporiz

1977 Arzew Algeria NA1 workerfrozen todeath

NA Yes

Aluminum vatemperaturesreplacement ignition (LNG

1977 LNG Aquarius Loading No No Yes Tank overfille

1979Columbia GasLNG Terminal

Cove Point,Maryland,US

NA

1 killed,1seriouslyinjured

Yes Yes

An explosion substation. LNelectrical pen

through 200 fconduit, and enatural gas wthere were nobuilding. The breaker igniteresulting in anterminal)

1979Mostefa Ben-Boulaid Ship

? Unloading No Yes Yes Valve leakage

1979 Pollenger Ship ? Unloading No Yes Yes Valve leakage

1979El Paso PaulKayser Ship At sea No Yes No

Stranded. Sev

tanks, motorscontainment s

1980 LNG Libra At sea No Yes No Shaft moved

1980 LNG Taurus In port No Yes NoStranded. BalExtensive bot


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Major LNG Incidents

IncidentDate

Ship/FacilityName

LocationShipStatus

Injuries/Fatalities

Ship/PropertyDamage

LNG Spill /Release

Comment

1984 Melrose At sea No Yes NoFire in engine

sustained - lim

1985 Gradinia In port NoNotreported

NoSteering gearreported.

1985 Isabella Unloading No Yes YesCargo valve ffractures.

1989 Tellier Loading No Yes Yes Broke moorin

1990 Bachir Chihani At sea No Yes NoSustained strustressing and

1993Indonesianliquefactionfacility

Indonesia NA No NA NA

LNG leak frommodification punderground underwent a

overpressuredStorm sewer

2002LNG shipNorman Lady

East of theStrait ofGibraltar

At sea No Yes No

Collision with attack submaballast conditseawater into

2004 Skikda I Algeria NA

27 killed56 injured(Thecasualtiesare mainlydue to theblast, fewcasualtiesdue tofire)

NA NA

On J anuary 2(cold boxes, b

The fire compand 20, althoufacilities or thlocated at thepending until investigation.

Sources: University of Houston, "LNG Safety and Security," October 2003. http://www.beg.utexas.edu/energyecon/lng/. Cited wiat the Skikda Plant: Description and Preliminary Conclusions", March 2004.


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C3-2

MARINE SAFETY AND SECURITY

REQUIREMENTS


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March 2006 C3.2-1 Cabrillo Port Liquefied Natural Gas Deepwater PortRevised Draft EIR

MARINE SAFETY AND SECURITY REQUIREMENTS

1 Structural Safety Features of the FSRUSome of the major safety features of the FSRU required that would reduce the likelihood of anaccidental cargo release and would mitigate any release, regardless of cause are listed in thefollowing table.

Safety Feature Descr iption

Double HullConstruction

The FSRU and LNG carriers would be constructed with an outer and inner hull toprovide protection against collisions and resultant cargo loss. These hulls areseparated from each other by structural members and separated from the Mossspherical tanks by the tank mounts. Thus a collision would need to penetrate threelayers to result in cargo spillage.

Separation ofcargo holds andpiping systems

IGC code requires the structural separation of cargo holds from other spaces, aswell as separation of cargo piping from other piping systems. Amongst other things,this helps keep cargo leaks away from potential ignition sources and keeps cargofrom inadvertently being pumped through the wrong pipes.

Accessibility forInspection Access

IGC code requires that a tank be constructed so that at least one side is visible andaccessible to inspectors. This allows proper periodic inspection of the tank forintegrity and signs of corrosion or stress.

Leak Detectors inHold spaces

IGC code requires that gas detectors and low temperature sensors be placed in acargo hold in order to cargo leakage. An alarm sounds if either is detected andappropriate repairs and precautions can be undertaken.

TankRequirements forCargoContainment

ICG code requires that a tank be constructed with materials that can withstand thetemperatures involved so as to properly contain the cargo, and have adequate reliefvalve systems to avoid over pressurization.

Structural Analysis IGC code requires structural analysis of the cargo containment system and specifies

individual tank stress limitations.

Secondarycontainment andthermalmanagement

IGC code requires partial secondary containment to contain leaks and preventcontact of cryogenic liquid with the inner hull. This prevents thermal stress. Inaddition, insulation in conjunction with a primary and backup heating system mustbe installed that would keep the cargo from exceeding the thermal limitations of thematerial selected for the inner hull should the leak prevention system fail.

Tank Constructionand TestingRequirements

IGC codes address standards for workmanship, quality, and testing of tanks underconstruction. Each tank on the FSRU will have had its welds non-destructively tested, andhave had a pressure test to insure integrity before cargo is pumped aboard.

Isolation,

Construction andTestingRequirements forPiping and PressureVessels

IGC code specifies piping thickness, leak testing, pressure testing, isolation

requirements, welding requirements and many other aspects of pressure vessel andpiping design and construction. This insures the integrity of these systems beforeany cargo is brought aboard.


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Safety Feature Descr iption

EmergencyShutdown Valvesand ShutdownSystems

IGC code requires remote control shutdown systems for ceasing of cargo and vaportransfer in an emergency. This system must have the ability to be activated from atleast two locations on board the FSRU and will also be automatically activated inthe event of a cargo fire.

Pressure VentingSystems

IGC code specifies that appropriate venting of the cargo be installed to keep thecargo under the design pressure of the tank and keep relief valves from needing tooperate. The FSRU will use some of this gas for fueling the SubmergedCombustion Vaporizers, and will add the rest to the gasified product being pumpedto shore.

Vacuum ProtectionSystems

IGC code requires the installation of relief valves that would prevent underpressurization of cargo tanks in the event that cargo was pumped out withoutadequately providing for vapor return. The FSRU will have sufficient vapor returncapacity to keep the pressures at appropriate levels, however this system willprevent under pressurization should this system fail to be actuated or fail to workproperly.

Fire Protection

Systems

IGC code requires that LNG carriers have a saltwater fire main system for fighting

fires throughout the ship, and fixed dry chemical and CO2 systems for cargo areasand compressor rooms, respectively.

Cargo TankInstrumentation

IGC code requires that each cargo tank be outfitted with an integratedinstrumentation/alarm system that notifies the crew of possible leaks via gasdetection and temperature sensors; and tank liquid levels, temperatures andpressures. These systems, as well as the pressure relief systems mentionedabove, provide many-layered protection against cargo release either throughequipment malfunction or human error.

Additional GasDetection Systems

IGC code also requires gas detection systems and alarms in spaces where cargo islocated, including compressor spaces, spaces where fuel gas is located, and otherspaces likely to contain gasified cargo. Venting systems for certain spaces andportable gas detectors are also required.

Automatic SafetyShutdownSystems

IGC code requires that cargo loading areas and the docks be equipped with LNGvapor and fire detection systems that automatically shut down the transfer systemsin the event of a leak or fire. These shutdowns can also be manually operated bypersonnel on the dock (in this case, the FSRU) or LNG carrier.

Loading ArmEmergencyRelease Couplings

The FSRU loading arms are designed to isolate the flow of cargo and break awayfrom their connection to the carrier if relative motion exceeds safety parameters.

This prevents damage to the arms, and averts the spill of cargo which would resultfrom a broken arm. Quantities spilled during this process would be only a fewgallons, most of which would be caught in drip trays to prevent deck thermaldamage.

2 Operational Measures for Accidental Release Prevention

In addition to the design regulations described above, the international and national entities withauthority to impose such regulations have also provided operational guidelines to reduce thelikelihood and impact of an LNG release aboard carriers. The FSRU, as a Deepwater Port ofthe United States, is primarily guided by the Deepwater Port Act as modified in 33 CFR 148 -150 by the Maritime Safety and Security Act and other legislation and agency determinations.


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These measures include:

Training,

Formal Operational Procedures, and

Inspections.

2.1 TrainingTraining requirements for crews of LNG carriers are specified in the IMO STCW Convention andthose for the FSRU are detailed in 33 CFR 150. A wide variety of training is included for both,including marine firefighting, water survival, spill response and clean-up, emergency medicalprocedures, hazardous materials procedures, confined space entry, and training on operationalprocedures. Specifics are also included in the below summary of the Deepwater PortOperations Manual requirements.

2.2 Formal Operational ProceduresBoth the FSRU and the visiting LNG carriers would be required to have formal operating plansthat cover an extensive array of operational practices and emergency procedures. LNG carriers

are required by the IMO to meet the ISM Code, which addresses preparing for responding toemergency situations like fire and LNG releases. The LNG carriers navigational, pollutionresponse, and some emergency procedures would also be covered in the Deepwater PortOperations manual, which addresses every aspect of the FSRU operations. The minimumcontents of this manual are detailed in 33 CFR 150. This manual provides detailed requirementsthat cover contingencies and normal operations. The operations manual must meet allrequirements set forth by the US Coast Guard, and be approved by that organization beforeoperations begin.

The operations manual is required by 33 CFR 150 to address the following areas:

The DWP facilities must be clearly described physically and geographically, applicable

codes for design and construction must be detailed, schematics of all systems must beincluded which show the positions of all operations and safety equipment. Thecommunications system must be described and communications procedures laid out.

Procedures for the visiting LNG carriers are also required to be included. Operatinghours must be set and sizes and types of tankers that may be received must bedescribed. Navigation standards for the LNG carriers must be set forth, includingoperating limits for each type of carrier. Speed limits for the safety zone must bespecified, as well as the means of tracking, communicating and giving routinginstructions to the carriers. Required notices that carriers must give prior to arrival mustbe detailed. Rules for navigating in the safety zone and for mooring/unmooring must bedetailed. Special equipment needed for mooring or navigating must be described.

Procedures for clearing all carriers and support vessels away from the FSRU in theevent of an emergency or for normal operations must be specified.

Weather forecasting and information dissemination procedures must be set forth.Specific weather limitations must be defined for carrier arrival, cessation of cargotransfer operations and departure of carriers from moorings in the event of adverseweather being forecasted or as it occurs unexpectedly. This includes defining conditionsin which the FSRU would be secured and evacuated.


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The manning requirements for all operational and emergency situations must bespecifically described, with personnel in charge of major evolutions designated by name,in writing. The supervisors would be reviewed by the US Coast Guard to ensure theyhave the proper qualifications and training to perform their duties.

Procedures for major evolutions, such as cargo transfers, must be set forth in detail.

Manning and training requirements, specific duties for watchstanders and supervisorsand emergency shutdown system settings must be detailed. Special precautions andhandling procedures for LNG must be included.

Maintenance program requirements and specific procedures are required to documentthe service and repair of cargo equipment, fire fighting systems, safety equipment andcranes.

Occupational Health and Safety training procedures and requirements must be detailed,including: housekeeping, illumination requirements, fall arrest equipment, personneltransfer systems, hazard communication, permissible exposure limits for hazardoussubstances, protective guards around machinery, electrical safety, lockout/tagout

procedures, crane safety, sling usage, hearing conservation, hot work, warning sirens,and confined space entry.

The security plan is part of the operations manual and is covered in detail in the below securitysection.

An environmental monitoring program also must be included, which describes procedures formonitoring the effects of the port on its surroundings. This must include periodic re-examinationof the physical, chemical and biological factors examined in the Environmental ImpactStatement, as well as air and water monitoring proscribed by other statutes and state law.Detailed studies are required in the event of a spill.

2.3 InspectionsThe US Coast Guard has the authority and jurisdiction to perform inspections of Project vesselsin U.S. waters, or on the high seas after a vessel states intent to moor at the DWP. Additionalinspections may be carried out on LNG carriers by their flag states, by classification societies,and by the owners. Per 33 CFR 150, the US Coast Guard also may inspect the FSRU at anytime, with or without notice, for safety, security, and compliance with applicable U.S. laws andregulations.

33 CFR 150 mandates that the FSRU be self inspected every 12 months by the owner oroperator to ensure compliance with applicable safety and security laws and regulations. Theresults must be reported to the US Coast Guard COTP within 30 days of completion, and maybe checked for accuracy by a Coast Guard inspection at any time. This report must include

descriptions of any failure, and the scope of repairs subsequently made. Any classificationsociety certification or interim class certificate must be reported to the COTP as well.

The US Coast Guard has marine inspection programs for ships, Outer Continental Shelfstructures, DWP Facilities and waterfront facilities. US Coast Guard Officers and Petty Officersreceive very detailed training on applicable regulations and inspection techniques. For thisproject, the most applicable Safety programs include the Port State Control program and 33


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CFR 160 for the inspection and routing of visiting ships, and the DWP inspection programspecified by 33 CFR 150.

Ports State Control of visiting vessels occurs by means of a US Coast Guard Boarding, targetedat determining the vessels compliance to international IMO standards for safety, pollutioncontrol, loading, and watch stander qualification, training and procedures. Vessel safety,

sanitation and cargo handling equipment is inspected, emergency drills and procedures may beran in order to determine crew proficiency, navigation practices are examined, and all pertinentplans, safety management systems and other required documents are examined. The required96-hour Notice of Arrival for these vessels allows the Coast Guard ample time to determinewhich vessels to board, whether to conduct the boarding in port or at sea, or even if entry isdenied pending an inspection.

The COTP decides which vessels are at highest risk for non-compliance with IMO conventionsthrough a process by which the following factors are considered: The owner, Flag State andclassification society of the vessel - some owners, flag states and classification societies have ahistory of poor inspection and regulation of their vessels; how many times and how recently avessel has been boarded or detained for violations previously; and the type of cargo the vessel

is carrying. The vessels having the most factors of concern are boarded immediately, whileothers may be boarded on subsequent entries into the U.S.

Vessels found to be in non-compliance with IMO standards may be recommended for furtherflag state or classification society audit, detained in port until their discrepancies are fixed,ordered to anchorage for the same purpose, or forbidden to enter U.S. waters.

33 CFR 160 gives authority to each US Coast Guard District Commander or Captain of the Portto order a vessel to operate or anchor in the manner directed when there is a suspectedviolation of law or treaty, there is a failure to satisfy the cargo transfer provisions of 33CFR160.113, or if justified by weather, visibility, port congestion or condition of the vessel.

33 CFR 160.113 Gives COTP the authority to prohibit a vessel from transferring cargo oroperating on the navigable waters of the US if the vessels history of accidents, pollutionincidents, or serious repair problems creates reason to believe that the vessel may be unsafe orpose a threat to the marine environment. It also allows these restrictions for other reasons: Thevessel is in violation of a law or regulation, has discharged oil or other hazardous substance inviolation of US law or treaty, fails to comply with Vessel Traffic Service requirements, or doesnot have at least one licensed deck officer on the navigation bridge that speaks English.

One of the relevant results of this inspection regimen is that every Project vessel and the FSRUwould be inspected at least yearly for compliance to all applicable IMO standards and U.S. laws.Equipment, training, qualifications, operating and emergency procedures, administrativecontrols, and most every other aspect leading to safe operation of the FSRU and project vessels

would be checked by the owners, the flag states (for vessels) and the United States forcompliance.

3 Secur ity Measures that Help Prevent Release Incidents Due to Deliberate AttacksRegulation and operational procedures play a vital role in the prevention of terrorist acts. Infact, much of what prevents or mitigates an accident will do the same for a terrorist act (doublehulls, fire suppression systems, etc). However, potential deliberate acts of terrorism expose theProject to new threats, many of which cannot easily be prevented, though mitigative actionsmay be nearly the same after the incident occurs.


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The foundation for the FSRU and visiting LNG carriers' security would be the requirements for asecurity plan outlined in 33 CFR 150. This plan would address security issues including, but notlimited to:

Access control for people, goods and material;

Monitoring and alerting vessels that approach or enter the ports security zone;

Identifying risks and measures to deter terrorist activity;

Internal and external notification requirements and responses in the event of a perceivedthreat or attack on the port;

Designating a Port Security Officer; providing identification means for port personnel;security training requirements;

Actions and procedures that are scalable to the threat; emergency procedures such asevacuation; special operations procedures (re-manning, refueling, diving, support vesseloperations and logistical concerns);

Recordkeeping for maintenance; and

Tests and operations outlined in the operations manual.

In addition, radar monitoring of the security zone is a required when any vessel approaches orenters the zone. Such vessels must be identified and warned off via radio.

3.1 Requirements to meet IMOs International Ship and Port Facilities Security Code(ISPS) CodeIMOs ISPS code has the following additional requirements:

Security levels;

Ship security plans;

Ship security alarm systems;

Automatic identification systems;

Port security plans;

Declarations of security; and

Facility security plans.

For the U.S., these IMO requirements are addressed in 33 CFR Subchapter HMaritimeSecurity.

3.1.1 Security levels

For the U.S., security levels are covered in 33 CFR 101, which ties the three tiered MaritimeSecurity (MARSEC) level to the five level Department of Homeland Security's HomelandSecurity Advisory System as the below table depicts.


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Homeland security advisory system Equivalent maritimesecurity(HSAS) threat condition (MARSEC) level

Low: Green MARSEC Level 1.

Elevated: BlueGuarded: Yellow

High: Orange MARSEC Level 2.

Severe: Red MARSEC Level 3.

Specific actions would be required of Project personnel at each level, and would be detailed inthe security plan for the FSRU and the Ship Security plans.

Changes in MARSEC level is communicated by the COTP via Broadcast NTM, and all who are

required to have a security plan (facilities, vessels must report attainment of measures in theirplan that correspond to the new MARSEC level to the appropriate Coast Guard DistrictCommander.

When the USCG determines it is necessary to enact additional measures to counter a maritimethreat, the USCG Commandant (or delegate) may issue a directive to those required to have asecurity plan (or portions of, as needed) to take additional security measures to counter thethreat. Reporting of attainment of the measure or its approved equivalent is carried out in thesame way as a change in MARSEC, but within a time period specified by the directive.

3.1.2 Vessel security plans 33 CFR 104 requires every vessel owner or operator who operates in U.S. waters to develop

and submit to USCG a vessel security plan. The regulations provide the format andrequirements for the plan. Vessel security plan implementation must be evaluated by anonboard verification by the flag state or a security organization recognized by the flag statebefore an International Ship Security Certificate (ISSC) can be issued for that vessel. Theseplans must include provisions for access to the ship by ship personnel, passengers, visitors, etc;restricted areas on the ship; handling of cargo; delivery of ships stores; handlingunaccompanied baggage; and monitoring the security of the ship. These measures areintended to prevent deliberate destructive act on board a vessel and the possible hijacking ofthe vessel for use as a weapon (ramming other vessels, bridges, blocking channels, releasingcargo near shore, etc).

Control and compliance measures for those vessels in violation of this requirement include the

vessels inspection, delay or detention. Vessel operations may be restricted, port entry into theU.S. denied, or the vessel may be expulsed from a U.S. port. Lesser administrative orcorrective actions may be taken. The vessels security plan is subject to USCG approval, whichmay be withdrawn, which would make it illegal for the vessel to operate in, on, under or adjacentto U.S. waters.


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3.1.3 Ship securi ty alarm systemsShip security alarm systems are required by the ISPS code for Project LNG carriers. Thesesystems are manually operated by the crew in the event of a terrorist destructive act orattempted takeover. An alarm does not sound on the vessel, but does automatically send asignal to appropriate authorities, such as the Coast Guard.

3.1.4 Automatic identification sys tems (AISs)As described in theabove vessel collision avoidance section, an AIS provides augmented datato radar users, which aid in the identification of vessels. The traffic controllers onboard theFSRU, the VTS and USCG responders would be able to locate and identify vessels outfittedwith AIS more quickly and accurately, thus decreasing confusion and response time to anemergency, including security alarm activations.

3.1.5 Port securi ty plansThe ISPS Code requires ports to have a port facility security officer and to develop a port facilitysecurity plan which must interface with the individual vessel security plans. In the UnitedStates, 33 CFR 103 mandates an Area Maritime Security plan which applies to all vessels andfacilities located in, on, under, or adjacent to waters subject to U.S. jurisdiction. This regulation

empowers the COTP to set up counsels to advise on port security, write and exercise the areasecurity plan and defines required elements of the plan. (ex. Plan must address actions to betaken for a change of MARSEC, what to do if a vessel security alert system is activated,estimated response and timeframe for a Transportation Security incident, etc)

3.1.6 Declarations of securityDeclarations of security are required by 33 CFR 101 for ports across the US, and are intendedto serve as the formal means by which the security actions of the vessel and port are agreedupon during mooring and cargo transfer operations. This declaration must be signed by thevessel and facility security officer prior to commencement of offloading.

3.1.7 Facili ty securi ty plans

Under the USCG maritime security regulations (33 CFR 105 Subpart D), LNG facilities thatreceive LNG carriers will have to develop a facility security plan. Like the vessel security plansthat have to meet the ISPS Code, the USCG regulations define areas the facility security planshave to address, including:

Security administration and organization of the facility;

Personnel training;

Drills and exercises;

Records and documentation;

Response to change in security level;

Procedures for interfacing with vessels;

Declaration of Security;

Communications;

Security systems and equipment maintenance;

Security measures for access control, restricted areas, handling cargo, delivery of vesselstores and bunkers, and monitoring;


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Security incident procedures; and

Audits and security plan amendments.

Like ship security plans, USCG must approve facility security plans. If the COTP deems awaterfront facility unsafe or insecure in any way by, vessels may be prevented from dockingthere, or be moved if already docked.

Other, control and compliance measures for facilities for violations of these requirementsinclude restriction on facility access, conditions being put on facility operations, suspension ofoperations, or revocation of approval for the facilitys security plan which makes it illegal for thefacility to operate.

3.1.8 Coast Guard operational measures applicable to security of the ProjectThe USCG, in addition to its inspection duties, is also an active enforcer of all applicablenational and international law on the high seas and within the waters of the United States. TheUSCG's enforcement of these laws will significantly add to the security of any nearby facility.

These actions may include:

Enforcement of 96-hour Notice of Arrival (NOA) requirements, including vetting crew andpassenger lists against terrorist and criminal databases.

Conducting regular patrols with aircraft and armed surface vessels to support MaritimeDomain Awareness (knowing what vessels are within or near U.S. waters).

Conducting Right of Approach questioning of any vessel to determine county of registry,last port of call, crew nationality and other useful data.

Conducting background intelligence checks on sighted vessels and like checks on thecrews of boarded vessels.

Monitoring all vessel traffic over 300 GWT with 25 NM of Pt. Fermin Light as part of VTSLA/LB (Note: this area is approx 5nm from the FSRU and covers approaches from the

West).

Conducting armed escorts of vessels deemed to be High Risk.

Placing Armed Sea Marshals on board High Risk vessels (Note: the determination toprovide escort or Sea Marshals for any Project vessel is at the discretion of COTP).

Conducting searches of vessels suspected of violating immigration, customs andnarcotics laws.

Inspecting the safety gear of all U.S. flagged and state registered pleasure craft andcommercial vessels.

Conducting searches of foreign vessels with flag state or Master's consent for evidence

of violation of applicable laws. Acting in accordance with the U.S. Military Standing Rules of Engagement to protect

U.S. citizens and property.

Patrolling, warning and boarding vessels to enforce security zones.


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Should the threat level or other circumstance dictate, the USCG and other military brancheswould take measures to provide for the security of the Project. The nearby presence of militaryvessels and aircraft conducting operations and surveillance of the Point Mugu Sea Range wouldalso augment Maritime Domain Awareness, and would periodically result in the presence ofarmed warships within relatively close proximity to the FSRU. All of these vessels could behailed on frequencies available in the FSRU communications centers, and all are allowed by the

rules of engagement to protect themselves, other U.S. military units, U.S. Citizens and propertyif being attacked.

The COTP may restrict anyone, or anything from entering a waterfront facility subject to U.S.jurisdiction or boarding a vessel subject to U.S. jurisdiction deemed necessary for safety orsecurity. Further, to prevent damage or injury to vessels or facilities or safeguard ports,territory, or waters of the U.S., COTP may establish a security zone, consisting of whateversections of water and land deemed necessary. No person or vessel may enter this zone orleave any article on a vessel or facility in this zone without COTP (or designee) approval. Anyvessel, facility or person in this zone may be inspected or searched, and items or persons maybe removed from the zone as deemed necessary. Guards may be posted on any vessel oranywhere in a security zone deemed necessary. Movements of vessels may be controlled as

necessary, and within the territorial seas of the U.S., the COTP may enlist the aid andcooperation of Federal, State, county, municipal, and private agencies to assist.

Licenses and required documentation may be required by the COTP for personnel entering awaterfront facility, who may revoke/not approve such based on deciding that the person is asecurity risk. An appeals process is set up, as is a board to hear such consisting of a CoastGuard Officer and members from company management and a labor representative.


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C3-3

DESIGN AND SAFETY STANDARDS

APPLICABLE TO NATURAL GAS

PROJECTS


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DESIGN AND SAFETY STANDARDS APPLICABLE TO NATURAL GASPROJECTS

Documents Incorporated by Reference into Title49 CFR Part 192, Appendix A, as amended

through June 14, 2004

Title (applicable edition)

A. American Gas Association (AGA)

(1) AGA Pipeline Research Committee, ProjectPR-3-805

A Modified Criterion for Evaluating the RemainingStrength of Corroded Pipe (AGA-PR3-805-1989).

B. American Petroleum Institute (API)

(1) API Specification 5L Specification for Line Pipe (42nd edition, 2000).

(2) API Recommended Practice 5L1 Recommended Practice for Railroad Transportationof Line Pipe (4th edition, 1990).

(3) API Recommended Practice 5LW Transportation of Line Pipe on Barges and MarineVessels (2

ndedition, 1996)

(4) API Specification 6D Specification for Pipeline Valves (Gate, Plug, Ball,

and Check Valves) (21st edition, 1994).

(5) API Standard 1104 Welding of Pipelines and Related Facilities (19thedition, 1999, including its October 31, 2001errata).

C. American Society for Testing and Materials (ASTM)

(1) ASTM Designation A 53/A53M-99b Standard Specification for Pipe, Steel, Black andHot-Dipped, Zinc-Coated, Welded and Seamless(ASTM A53/A53M-99b).

(2) ASTM Designation A 106 Standard Specification for Seamless Carbon SteelPipe for High-Temperature Service (ASTM A106-99).

(3) ASTM Designation A 333/A 333M Standard Specification for Seamless and WeldedSteel Pipe for Low-Temperature Service(ASTM A333/A333M-99).

(4) ASTM Designation A 372/A 372M Standard Specification for Carbon and Alloy SteelForgings for Thin-Walled Pressure Vessels(ASTM A372/A372M-1999).

(5) ASTM Designation A 381 Standard Specification for Metal-Arc-Welded SteelPipe for Use With High-Pressure TransmissionSystems (ASTM A381-1996).

(6) ASTM Designation A 671 Standard Specification for Electric-Fusion-WeldedSteel Pipe for Atmospheric and Lower

Temperatures (ASTM A671-1996).

(7) ASTM Designation A 672 Standard Specification for Electric-Fusion-WeldedSteel Pipe for High-Pressure Service at Moderate

Temperatures (ASTM A672-1996).

(8) ASTM Designation A 691 Standard Specification for Carbon and Alloy SteelPipe, Electric-Fusion-Welded for High-PressureService at High Temperatures (ASTM A691-1998).

(9) ASTM Designation D638 Standard Test Method for Tensile Properties ofPlastics (ASTM D638-1999).


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Documents Incorporated by Reference into Title49 CFR Part 192, Appendix A, as amendedthrough June 14, 2004


(10) ASTM Designation D2513-1987applies to 192.283(a)(1)

Standard Specification for Thermoplastic GasPressure Pipe, Tubing and Fittings (ASTM D2513-1987).

(11) ASTM Designation D2513-1999 Standard Specification for Thermoplastic GasPressure Pipe, Tubing and Fittings (ASTM D2513-1999).

(12) ASTM Designation D 2517 Standard Specification for Reinforced Epoxy ResinGas Pressure Pipe and Fittings (D 2517-2000).

(13) ASTM Designation F1055 Standard Specification for Electrofusion TypePolyethylene Fittings for Outside DiameterControlled Polyethylene Pipe and Tubing (F1055-1998).

D. The American Society of Mechanical Engineers, International (ASME) and American NationalStandards Institute (ANSI)

(1) ASME/ANSI B16.1 Cast Iron Pipe Flanges and Flanged Fittings(ASME B16.1-1998).

(2) ASME/ANSI B16.5 Pipe Flanges and Flanged Fittings(ASME/ANSI B16.5-1996, including ASMEB16.5a-1998 Addenda).

(3) ASME/ANSI B31G Manual for Determining the Remaining Strength ofCorroded Pipelines (ASME/ANSI B31G-1991).

(4) ASME/ANSI B31.8 Gas Transmission and Distribution Piping Systems(ASME/ANSI B31.8-1995).

(5) ASME/ANSI B31.8S Supplement to B31.8 on Managing System Integrityof Gas Pipelines (ASME/ANSI B31.8S-2002)

(6) ASME Boiler and Pressure Vessel Code,Section I

Rules for Construction of Power Boilers(ASME Section I-1998).

(7) ASME Boiler and Pressure Vessel Code,Section VIII, Division 1

Rules for Construction of Pressure Vessels(ASME Section VIII, Division 1-2001).

(8) ASME Boiler and Pressure Vessel Code,Section VIII, Division 2

Rules for Construction of Pressure Vessels:Alternative Rules(ASME Section VIII Division 2-2001).

(9) ASME Boiler and Pressure Vessel Code,Section IX

Welding and Brazing Qualifications(ASME Section IX-2001).

E. Manufacturers Standardization Society of the Valve and Fittings Industry, Inc. (MSS)

(1) MSS SP44-96 Steel Pipe Line Flanges (MSS SP-44-1996including 1996 errata).

F. National Fire Protection Association (NFPA)

(1) NFPA 30 Flammable and Combustible Liquids Code(NFPA 30-1996).

(2) ANSI/NFPA 58 Standard for the Storage and Handling of LiquefiedPetroleum Gases (NFPA 58-1998).

(3) ANSI/NFPA 59 Standard for the Storage and Handling of LiquefiedPetroleum Gases at Utility Gas Plants(NFPA 59-1998).


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Documents Incorporated by Reference into Title49 CFR Part 192, Appendix A, as amendedthrough June 14, 2004


(4) ANSI/NFPA 70 National Electrical Code (NFPA 70-1996).

G. Plastics Pipe Institute (PPI)

(1) PPI TR-3/2000 Policies and Procedures for Developing HydrostaticDesign Bases (HDB), Pressure Design Bases(PDB), and Minimum Required Strength (MRS)Ratings for Thermoplastic Piping Materials(PPI TR-3/2000-Part E only, Policy for DeterminingLong Term Strength (LTHS) by TemperatureInterpolation.

H. National Association of Corrosion Engineers International (NACE)

(1) NACE Standard RP-0502-2002 Pipeline External Corrosion Direct AssessmentMethodology (NACE RP-0502-2002).

I. Gas Technology Institute (formerly Gas Research Institute (GRI)

(1) GRI 02-0057 Internal Corrosion Direct Assessment of Gas

Transmission PipelinesMethodology(GRI 02/0057-2002).

DETERMINATION OF HIGH CONSEQUENCE AREAS

HCAs must be determined using one of two allowable methods described in 49 CFR

192.903, using the process for identification described in 49 CFR 192.905 and guidance

provided in an advisory bulletin (68 FR 42456, J uly 17, 2003). The length of the

pipeline subject to pipeline integrity assessments and mitigation actions the pipeline

segment encompassed by the HCA is also shown in these figures.

Where a potential impact circle is calculated using either Method 1 or Method 2 to

establish an HCA, the length of the HCA extends axially along the length of the pipeline

from the outermost edge of the first potential impact circle that contains either an

identified site or 20 or more buildings intended for human occupancy to the outermost

edge of the last contiguous potential impact circle that contains either an identified site

or 20 or more buildings intended for human occupancy.

The regulations also allow operators to prorate the number of buildings within an impactcircle until 2006. This exemption was intended to relieve the data collection burden on

operators of existing pipelines but should not be applied to the new pipeline construction

proposed for this Project. Pipeline operators are not required to use the same method

along the entire length of any pipeline.


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Method 2. The area within a potential impact circ le containing :

(i) 20 or more buildings intended for human occupancy, unless the exception in paragraph (4)applies; or

(ii) An identified site.

Paragraph (4) Exception: If the radius >660 feet (200 m), the HCA may be identified based on a prorated number ofbuildings intended for human occupancy within 660 ft from the centerline of the pipeline until December 17, 2006.

This exception was not intended for use for new pipelines.

Cluster of >20 homes

PIR

HCA

Cluster of >20 homes

HCA

Pipeline

660 ft (200 m)

PIR >660 ft (200 m)

Cluster of >

20 homes

PIR